Document rar0X3yE5RyDLg6295O49Jxq

October 30, 1972 Ur, L H, Soever ftaybesio^-Manhaiien, Inc, 123 E Stlogal Street ttanheim, Pa, 17545 Dear Ike* Enclosed are two copies of a survey on 0$HA labeling for our nsfibere, Please \00k this over, \ will not distribute till you give o>e the go-ahead. Sincerely,* Encs, t, %, Brisbane Executive Director WV-06023 7=;-71 Oh I^ATcRiALS STANDARDS if;57iTJ7, IIC., c-2?C r^.Z *4, rn^% October 30, 7972 wr* TO: Del agates & Alternates Asbestos Study CoatBitiee SU3JCTs interpretation of OSHA Labeling Retirement* The Chairwan of the Asbestos Study Cacmsittee is requesting * survey of members on their interpretation of the labeling requirements for asbestos type brake lining and clutch facing shipments. On June 20, 1972, the Institute distributed to all members a copy of the OSHA Standards for exposure to asbestos dust. A key paragraph in ihe standards had to do with labeling requirements: (2) Caution labels--(i) Labeling. Caution labels shall be affixed to all raw materials, mixtures, scrap, waste, debris, and other products contain ing asbestos fibers, or to their containers, except that no label is required where asbestos fibers have been codified by a bonding agent, coating, binder, or other material so that during any reasonably foreseeable use, handling, storage, disposal, processing, or transportation, no airborne concentrations of asbestos fibers in excess of the exposure limits prescribed in paragraph (b) of this section will be released. The problem, in this case, is the shipment of asbestos containing brake linings or clutch facings where in many cases subsequent operations will be performed--cutting, grooving, drilli*^, and grinding. The Chairman indicates that these subsequent operations can produce airborne concentrations of asbestos fibers in excess of the current exposure limits (5 fiber s/e TWA, or 10 fibers/ee ceiling). The questions are: 1. Eb vou nor label asbestos type friction materials with the label as specified in the OSHA Standards? 1.7 for replacement .carkei shipments? 1.2 For original equipment shipments? 2. D> vou plan_t? label asbestos type friction materials with this label? 2.1 For replacement market shipments? 2.1 For original equipment shipments? 3. Do vou interpret the OSHA Regulations on label ing to require a manufacturer to label asbestos type friction materials where subsequent operations (drilling, grind* ing, etc.) are likely to be performed? Bould you olease complete this--or have it done by the individual responsible for implementation of the OSHA Standards--and return to ms at the Institute Office. . W, Dr is) ana Executive Director ICTICN MATERIALS STANDARDS INSTm/Tf, tt., -250 Route ft*ramus, *V. ... C7&52 BULL 'T!H NO, i.5 7 October 20, 1972 TO: ACTIVE MEMBERS ASBESTOS STUDY COM ITT EE LICENSEES SUBJECT: Occupational Safety and Health Standards (OSHA) In the October IS, 5972 issue of the federal Register, the Department of Labor issued a complete set of Rules and Regulations for the OSHA Stan dards. As regards asbestos, the section (1910.93a) pertaining thereto is unchanged from that sent to the membership with our Bulletin 442 of June 20, 1972. The Department published these to bring in all amendments to the standards through September 22, 1972, The purpose was (l) to publish the OSHA Siandards fully and reflect changes made during the year, (2) to correct typographical and clerical errors in the original standards, and (3) to publish an index with the standards. As these full standards are a bulky 250 page \ssue, tt ts suggested that members interested in acquiring up-dated standards request them from: * Superintendent of Documents U* S. Government Rrinting Off ice Washington, D. C. 20402 tf interested, order the federal Register of October TB, T972, wrth payment of 20 cents payable to Superintendent of Documents. , %. Drislane Executive Director FRICTION MATERIALS STANBA3BS INSTITUTC, INC., C-2JC SOi/T 4, rAR/WLlS, lr*> November c, i?/* TO: Delegates & A1 terries Asbestos Study Corrosittee SUg^CT: Interpretation of 0$HA Labeling Requirements The Chairman of the Asbestos Study Committee is requesting a survey of members on their interpretation of the labeling requirements for asbestos type Wake lining and clutch facing shipments. On <Aine 20, 1972, the Institute distributed to ail members a copy of the OSHA Standards for exposure to asbestos dust- A key paragraph in the standards had to do with labeling requirements* (2) Caution labels--(i) labeling. Caution labels shall be affixed to all raw materials, mixtures* scrap, waste, debris, and other products contairk ing asbestos fibers, or to their containers, except that no label is required where asbestos fibers have been modified by a bonding agent, coating, binder, or other material so that during any reasonably foreseeable use, handling, storage, disposal, processing, or transportation, no airborne concentrations of asbestos fibers in excess of the exposure limits prescribed in paragraph (b) of this section will be released. The problem, in this case, is th shipment of asbestos obtaining brake linings or clutch facings where in many cases subsequent operations will be performed--cutting, grooving, drilling, and grinding. The Chairman indicates that these subsequent operations can produce airborne concentrations of asbestos fibers in excess of the current exposure limits (5 fibers/cc TWA, or 10 fibers/cc celling). The questions ares 1. 3o vou now label asbestos type friction materials with the label as specified in the O&iA Standards? 1.1 For replacement market shipments? 1.2 Fof original equipment shipments? 2. Eb you plan to label asbestos type friction materials with this label? 2.1 For replacement market shipments? 2.1 For original equipment shipments? 3 Do vou interpret the OSKA Regulations cn labeling to require a manufacturer to label asbestos type friction materials where subsequent operations (drilling, grind ing, etc.) are likely to be performed? Sould you please cooplete this--or bm it done by the individual responsible for implementat ion of the OSHA St andards--and return to me at the lssrSs?e S=S*ss. , 8. trtSlarm FriCTlOW f.'.AT5Ufli-S STANDARDS INSTITUTE, -2*0 hOUU i- PARA'.'US, <v, C7652 & r OSHA LABEL IMG RCOIIREtoEMTS 1. Current labeling Practice Yas 1.1 For replacement market friction material shipments, we now provide the OSHA caution label. () 1.2 For original equipment friction material shipments, we now provide the OSHA caution label. () 2. Planned Labeling Practice 2.1 For replacement market friction material shipments, we plan to use the OSHA caution label. () C 2.2 For original equipment friction material shipments, we plan to provide the OSHA caution label. 3. fnteroretation of OSHA Labeling Regulations 3.1 be interpret the OSHA labeling regulations to require caution labels on friction material shipments that will have subse-, quent working (drilling, grinding, etc.}. () Sst () () () () S) V' BY COMPANY DATE